FILED Department of Business and Professional Regulation Deputy Agency Clerk STATE OF FLORIDA CLERK Evette Law: Proct DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULAT cas 7/96/0012 File # DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, BOARD OF ARCHITECTURE AND INTERIOR DESIGN, Petitioner, VS. CASE NO.: 2012-008402 RAM A. GOEL AND SONEY FM, LLC, Respondents. / ADMINISTRATIVE COMPLAINT Petitioner, DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, ("Petitioner"), files this Administrative Complaint before the Board of Architecture and Interior Design against RAM A. GOEL and SONEY FM, LLC, (“Respondents”), and says: I. Petitioner is the state agency charged with regulating the practice of architecture and interior design pursuant to Section 20.165, Florida Statutes, and Chapters 455 and 481, Florida Statutes. 2. The Department of Business and Professional Regulation has jurisdiction over the unlicensed practice of architecture pursuant to Section 455.228(1), and Section 481.223(1)(a), Florida Statutes. 3. Respondents’ last known address is 16306 Doune Court, Tampa, FL 33647. 4, At all times material hereto, Respondents were not duly registered or certified to engage in the practice of architecture pursuant to Chapter 481, Florida Statutes. Filed September 4, 2012 3:17 PM Division of Administrative Hearings 5. Majed M. Hawari (“Hawari”) entered into a contract to provide architectural services for a commercial project known as Garden Avenue Complex, located at 503 Marshall Street, Clearwater, Florida 33765. 6. At all times material hereto, Hawari was not duly registered or certified to engage in the practice of architecture pursuant to Chapter 481, Florida Statutes. 7. Hawari prepared architectural drawings for the project. 8. Hawari received compensation for providing architectural drawings for the project. 9. Hawari was doing business as All Architecture, Inc. 10. Hawari is not licensed in the State of Florida to practice architecture and therefore cannot offer or provide architectural services. 11. Respondent, a Florida licensed Professional Engineer, signed and sealed the drawings prepared by Hawari for the purposes of obtaining a building permit. 12. Further, Respondents are offering architectural services on their web site. 13. Respondents are not licensed to practice architecture in the State of Florida and therefore cannot offer or provide architectural services. COUNTI 14, Petitioner hereby realleges and incorporates paragraphs one (1) through thirteen (13) as if fully set forth herein. 15. Section 455.227(1)(j), Florida Statutes, prohibits aiding, assisting, procuring, employing, or advising any unlicensed person or entity to practice a profession contrary to this chapter, the chapter regulating the profession, or the rules of the department or the board. 16. Based upon the foregoing, Respondent has violated Section 455.227(1)G), Florida Statutes, by assisting Hawari in his performance of unlicensed activity contrary to Chapter 481, Florida Statutes. COUNT IH 17. Petitioner hereby realleges and incorporates paragraphs one (1) through thirteen (13) as if fully set forth herein. 18. Section 481.223(1)(a), Florida Statutes, states that a person may not knowingly “yractice architecture unless the person is an architect or a registered architect.” 19. Based upon the foregoing, Respondents have violated Section 481.223(1){a), Florida Statutes, by practicing architecture when they were not the holder of a valid license by offering architectural services on their web site, COUNT I 20. Petitioner hereby realleges and incorporates paragraphs one (1) through thirteen (13) as if fully set forth herein. 21, Section 481.219(2), Florida Statutes, requires a certificate of authorization for a corporation, partnership, or fictitious name offering architectural services. 22, Based upon the foregoing, the Respondent, Soney FM, LLC, has violated Section 481.219(2), Florida Statutes, by offering architectural services without a certificate of authorization. WHEREFORE, Petitioner respectfully requests the Board enter an Order imposing an administrative fine not to exceed $5,000 per count, assess costs associated with investigation and prosecution, impose any or all penalties delineated within Section 455.227(2), Florida Statutes, and/or any other relief that the Board is authorized to impose pursuant to Chapters 481 and 455, Florida Statutes, and/or the rules promulgated thereunder. rd Signed this 23 day of Toy , 2012. i ae / oy DAVID K. MINACCI Smith, Thompson, Shaw, Minacci & Colon, P.A. 3520 Thomasville Road, Fourth Floor Tallahassee, Florida 32309 FL Bar No. 0056774 Ph: (850) 402-1570 Fax: (850) 241-0161 PCP: July 16, 2012 Hall Shore Gozdz

Docket for Case No: 12-002902